Little consensus in early FirstNet comments

The National Telecommunications and Information Administration (NTIA) delayed the deadline for public comments on issues related to the Nationwide Public Safety Broadband Network (NPSBN) due to the impact of Hurricane Sandy. However, a number of comments were filed by the original deadline and show a range of opinions regarding network design as well as initial steps that the First Responder Network Authority (FirstNet) should take to establish the 700 MHz public-safety LTE network.

Due to the devastation caused by Hurricane Sandy along the Eastern seaboard, the deadline for comments was extended from Nov. 1 to Nov. 9. Comments were sought on business models and the design proposal for the FirstNet Nationwide Network (FNN), which was presented on Sept. 25 by FirstNet board member Craig Farrill.

Farrill cited three NPSBN implementation options: Build a standalone network, work with a single nationwide wireless operator or create a diverse nationwide network with multiple wireless networks and systems. He noted the idea of building a standalone network is "unworkable" and advocated for the third option.

Network Implementation Options - FirstNet

Source: FirstNet Nationwide Network

General Dynamics C4 Systems recommended FirstNet combine options one and three, saying such an approach would improve on the proposed FNN through better distribution, open competition, transparency, vendor neutrality, primacy of Band Class 14, maximal leveraging of assets, opt-out neutrality, user-level interoperability and security. "We further propose a robust acquisition strategy that centralizes management and decentralizes execution," said the company.

The vendor also pushed for resumption of paused 700 MHz public-safety communications activity. After the February passage of the Middle Class Tax Relief and Job Creation Act of 2012, which set aside 700 MHz D Block spectrum for the NPSBN and established FirstNet within NTIA as an independent authority, NTIA asked Broadband Technology Opportunities Program (BTOP) grant recipients to delay or suspend certain expenditures for their planned public-safety 700 MHz LTE networks and requested that the FCC revoke the waivers issued to 21 jurisdictions (BTOP or not) for such networks.

General Dynamics addressed mission-critical voice over LTE (VoLTE) as well. "In the short term, most commercial carriers are planning to leverage LTE not for voice, but rather for data," said the company, adding that VoLTE does not support mission-critical voice. The new NPSBN "needs point-to-multipoint bearers to be efficient in carrying group calls in major incident situations where large numbers of member of a call group are on one sector of a cell site," which would require additional features in provider radio access networks (RANs) and Evolved Packet Cores (EPCs), said the company.

Aircom's comments supported the FNN proposal for a blended diverse nationwide network with multiple wireless networks and systems. "The Active RAN Sharing technology specified by the 3GPP standards and its implementation by the OEMs offers FirstNet a platform and a road to deploy a logically independent network by sharing the majority of the RAN active and passive infrastructure," said Aircom.

The company recommended creation of an isolated and independent nationwide core network with integrated network operations centers (NOCs), noting that if the LTE network's "heart" is shared "then the risk of the network, data and users of being compromised and breached is high."

In its comments, industry trade group PCIA suggested FirstNet collaborate with wireless infrastructure providers in a public-private partnership. "If FirstNet's goal is to construct the PSBN swiftly and efficiently, it should take advantage of the purpose-built towers, rooftop installations, distributed antenna systems ("DAS") and small cells that the wireless infrastructure industry has worked hard to deploy," said PCIA.

In joint comments, seven states focused on FirstNet business issues. Idaho, Montana, Nevada, Oregon, South Dakota, Utah and Wyoming said the FirstNet board first needs to develop a business plan for the NPSBN, including creation of a cost model, a strategic marketing plan, preparation of a financial analysis and consideration of PSBN governance principles.

The seven also requested establishment of an advisory committee specifically for states and asked that First Net facilitate early deployment in those states that are funded and ready to proceed with interoperable network assets. "Such early deployment projects can help demonstrate the value of the network while also acting as a test bed for the larger PSBN deployment efforts," said the states.

For more:
- see this NTIA release and this public notice
- see filed comments on this NTIA webpage

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